RS-13-031, Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

ML13063A323
Person / Time
Site:	LaSalle
Issue date:	02/28/2013
From:	Kaegi G Exelon Generation Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
EA-12-051, RS-13-031
Download: ML13063A323 (10)

Text

Exelon Generation Order No. EA-12-051 RS-13-031 February 28,2013 u.s. Nuclear Regulatory Commission AnN: Document Control Desk Washington, DC 20555-0001 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374

Subject:

Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

References:

1. NRC Order Number EA-12-051, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012

2. NRC Interim Staff Guidance JLD-ISG-2012-03, "Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation," Revision 0, dated August 29, 2012

3. NEI 12-02, IndustryGuidance for Compliance with NRC Order EA-12-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," Revision 1, dated August24,2012

4. Exelon Generation Company, LLC's Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated October 25, 2012 On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Exelon Generation Company, LLC (EGC). Reference 1 was immediately effective and directs EGC to have a reliable indication of the water level in associated spent fuel storage pools. Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 requires submission of an Overall Integrated Plan by February 28, 2013. The NRC Interim Staff Guidance (ISG) (Reference 2) was issued August 29, 2012 which endorses industry guidance document NEI 12-02, Revision 1 (Reference 3) with clarlfications and exceptions identified in Reference 2. Reference 3 provides direction regarding the content of this Overall Integrated Plan. The purpose of this letter is to provide the Overall Integrated Plan pursuant to Section IV, Condition C.1 , of Reference 1. This letter confirms EGC has received Reference 2 and has an Overall Integrated Plan complying with the guidance for the purpose of ensuring a reliable indication of the water level in associated spent fuel storage pools capable of supportlng identification of required wide range pool water level conditions by trained personnel .

U.S.

U.S. Nuclear Regulatory Commission Integrated Plan Report Integrated Plan Report toto EA-12-051 EA-12-051 February 28, 2013 February 28, 2013 Page 2 Page Reference Reference 44 provided provided the EGC initial the EGC initial status status report report regarding regarding reliable reliable spent fuel pool spent fuel pool instrumentation, instrumentation,as as required requiredby byReference Reference 1. 1.

Reference Reference 3, 3, Appendix Appendix A-2 A-2 contains contains the specific reporting the specific reporting requirements requirements for for the Overall Integrated the Overall Integrated Plan. The information Plan. The information inin the the enclosure enclosure provides providesthetheLaSalle LaSalleCounty CountyStation, Station,Units Units11andand22Overall Overall Integrated Integrated Plan Plan pursuant pursuant to to Appendix AppendixA-2 Reference3.3. The A-2ofofReference The enclosed Integrated Plan enclosed Integrated Plan isis based based on on conceptual conceptual design design information.

information. FinalFinal design design details details andand associated procedure guidance, associated procedure guidance, as as well well asas any revisions to any revisions to the the information information contained contained in in the the Enclosure, Enclosure,willwill be be provided provided inin the the 6-6-

month month Integrated Integrated Plan Plan updates required by updates required by Reference Reference 1. 1.

This This letter letter contains contains nono new new regulatory regulatory commitments.

commitments. If If you you have any questions have any questions regarding regarding this this

report, report, please contact David please contact David P. P. Helker Helker at at 610-765-5525.

610-765-5525.

II declare under penalty declare under penalty ofof perjury perjury that that the the foregoing foregoing is is true true and and correct. Executedon correct. Executed onthethe28"' day 28th day of of February February 2013.

Respectfully submitted, Glen Glen T. Kaegi Director - Licensing Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

1. LaSalle County

1. LaSalle County Station, Units 1 Station, Units 1 and and 22 Reliable Reliable Spent Spent Fuel Fuel Pool Pool Instrumentation Instrumentation (SFPI)

(SFPI)

Overall Overall Integrated Plan cc: Director, Office ofof Nuclear Nuclear Reactor ReactorRegulation Regulation NRC Regional Administrator Administrator -- Region Region IIIIII NRC Senior NRC Resident Inspector Senior Resident Inspector -- LaSalle LaSalle County County Station, Station, Units Units 11 and and 22 NRC Project NRC Project Manager, Manager, NRR NRR -- LaSalle LaSalle County County Station, Station, Units Units 11and and22 Mr. Robert Mr. Robert J.J. Fretz, Fretz, Jr, Jr,NRRIJLD/PMB, NRRIJLD/PMB, NRC NRC Mr. Robert L. L. Dennig, Dennig, NRRIDSS/SCVB, NRRIDSS/SCVB, NRC NRC Illinois Emergency Management Agency Agency -- Division Division of of Nuclear Nuclear Safety Safety

Enclosure Enclosure 11 LaSalle LaSalle County County Station, Units 11 and Station, Units and 22 Reliable Spent Fuel Reliable Spent Fuel Pool PoolInstrumentation Instrumentation(SFPI)

(SFPI)

Overall Integrated Plan Plan (7

(7 pages) pages)

LaSalle LaSalle CountyCounty Station.

Station, UnitsUnits 11 and and 2 Reliable Reliable Spent Spent Fuel Pool Pool Instrumentation Instrumentation Overall Integrated Plan Applicability:

This integrated plan applies to LaSalle County Station, Units 11 and 2 and and is consistent with the requirements of Order EA-12-051 EA-12-051 and the guidance in NEI 12-02. Exelon's Exelon's six-month six-month reports reports will will progress made, delineate progress made, any proposed changes in compliance methods, updates to the schedule and, if needed, requests for relief relief and the basis.

basis.

General

Description:

LaSalle County Station is a two unit BWR Station. The two units share a common Reactor Building (RB) (RB) refueling floor and two interconnected Spent Fuel Pools (SFPs). Normal SFP water level is approximately at elevation 842' 6".6". The The top top of of the the spent spent fuel fuel racks racks is is at at 819' 819'53/4" 5 %" in the Unit 11 SFPSFP and and 819' 819' 83/4" 8 %" in the Unit 2 SFP, the top of active fuel is approximately 818' 4 %",and 818' 4'/s", andthe thebottom bottomofofthetheTransfer TransferCanal Canalisisatat elevation 820' 2".

elevation Note: InInall all subsequent subsequentdiscussions discussionsininthisthisplan planunless unlessotherwise otherwisenoted, noted,the thedimension dimensionofofthe thetop topofofthe the fuel racks in either unit will be conservatively considered at elevation 820'. 820' .

Schedule:

The installation of reliable level instrumentation for the SFPs associated with Unit 11 and Unit 2 is scheduled for completion by the end end ofof L2R15 L2R15 (Spring (Spring 2015) 2015)based basedononthe theend endofofthe thesecond secondrefueling refueling outage for Unit 2 following submittal of of this integrated plan (per NRC Order EA-12-051). L2R15 L2R15isisthethe earlier outage sequence of the units discharging to the pools. Unit Unit11and andUnit Unit22discharge dischargeirradiated irradiatedfuel fuel to a set of of two interconnected interconnected spent spent fuel fuel storage storage pools.

pools. With the exception of of limited limited time time periods periods for for maintenance or non-refueling non-refueling operations, operations, administrative administrativecontrols controlswill willmaintain maintainthe thegates gatesbetween betweenthe the following pools open: Unit Unit11SFP SFPand andthe theCask CaskStorage StoragePit,Pit,and andUnit Unit22SFPSFPandandthe theCask CaskStorage StoragePit.Pit.

Therefore, the Unit 11 and Unit 2 pools are are normally interconnected and and atat the same water level when the water level in either SFPSFP is is greater greater than than nominally nominally 11foot footabove abovethe thetop topofofthe thespent spentfuel fuelstorage storageracks.

racks.

The current milestone milestone schedule schedule isis as as follows:

follows:

• Complete Conceptual Design Design (CD)

(CD) forfor Pilot PilotPlant Plant(Limerick)

(Limerick) Complete

• Complete CD Follow-up Walkdowns at at Remaining 99 Exelon Exelon Sites Sites Complete

• Submit Initial 60 day Status Report Complete

• Develop Request for Proposal for Detailed Engineering Complete Design Services

• Submit Initial 6060 Day Day Status Status Report Report Complete

• Submit Integrated Integrated Plan Plan Complete withwith this submittal submittal

• Begin Detailed Detailed Engineering Engineering Design Design 2Q 2013

• Procure SFPSFP Instrumentation Instrumentation 4Q 2013 2013 1I 1I

LaSalle LaSalle County County Station, Station, UnitsUnits 1 1 and and 22 Reliable Spent Fuel Pool Instrumentation Reliable Spent Fuel Pool Instrumentation Overall Integrated Plan

• Complete and Issue SFPI Modification Modification Package Package 4Q 2013

• • Begin SFPI Installation 4Q 2014

• Complete SFPI Installation and Put Into Service Service I Q 2015 1Q Identification of Spent Fuel Pool Water Levels:

Key spent fuel pool water levels will be identified Key identified asas follows:

follows:

adequate to Level adequate to support operation of the normal fuel fuel pool cooling system (Levell): (Level 1): For both units, indicated level on either primary or backup instrument channel must be greater than 842' 1" 1" to to maintain normal operation of the Fuel Pool Cooling system. 842' 1" 1" isis the the elevation elevationof ofthe thebottom bottomof of the fuel pool weirs which maintain the flowpath for re-circulation of water from the pool through the system.

Level adequate Level adequate to to provide provide substantial substantial radiation shielding for a person standing on the spent fuel pool operating deck (Level 2): For Forboth bothunits, units,indicated indicatedlevel levelon oneither eitherthe theprimary primary oror backup backup instrument channel of greater than 10 10 feet plus plus instrument instrument channel channelaccuracy accuracyabove abovethethetop topofofthe the storage racks.

storage racks. The The specification of thisthis level level is is based on JLD-ISG-2012-03 JLD-ISG-2012-03 and NEI 12-02. This This monitoring level ensures there is an adequate water level to to provide substantial radiation shielding for a person standing on the spent fuel pool operatingoperating deck deck from from direct directgammagan1maradiation radiationfrom fromstored storedfuel.

fuel.

Level where fuel remains covered (Level 3): For Forboth bothunits, units, indicated indicated levellevel on on either either the the primary primary or or backup instrument channel of greater than 0 feet (elevation 820') plus plus instrument instrument channel channel accuracy accuracy above the top of the storage racks based upon the the design design accuracy accuracy (which (which isisto tobebedetermined) determined)ofofthe the instrument channel for both the primary and backup instrument channels. This Thismonitoring monitoringlevel level assures that water is covering the stored fuel seated seated in the the racks.

racks.

Instruments:

The design of ofthe the instruments instruments will be be consistent consistent with with the the guidelines guidelines of NRC JLD-ISG-2012-03 JLD-ISG-2012-03 and and NEI NEI 12-02. Specifically, Specifically,the thechannels channelswill willbebedesigned designedas asdiscussed discussedbelow:

below:

Primary (fixed) instrument instrument channel:

channel: The primary instrument channel level sensing components will be located and permanently mounted in the Unit 1 SFP. The Theprimary primaryinstrument instrumentchannel channelwillwill provide continuous level indication over a minimum range from the the high high poolpool level level elevation elevation of of 842' 842' 7 3/a" 3M" totothe thetop topof ofthe thespent spentfuel fuelracks racksatatelevation elevation 820'.

820'. This continuous level indication indication will will be be provided by aa guided guided wave wave radar radar system, system, submersible submersiblepressure pressuretransducer, transducer,ororother otherappropriate appropriatelevellevel sensing technology that will be determined during the detailed engineering design phase of of the project.

Backup instrument instrument channel:

channel: TheThebackup backupinstrument instrumentchannel channellevellevel sensing sensing components components will will be located and permanently mounted in the Unit 2 SFP. The Thebackup backupinstrument instrumentchannel channelwill willprovide provide continuous level level indication indication over over aa minimum minimumrange rangefrom fromthethehigh highpoolpoollevel levelelevation elevationofof842'842'7 73/a" 3M"to to the top of the spent fuel racks at elevation 820'. 820' . This This continuous continuous level level indication indicationwill willbebeprovided providedby by the same level sensing sensing technology technology asas the the primary primaryinstrument instrumentchannel.

channel.

21 21

LaSalle County LaSalle County Station, Units 1 and 22 Reliable Spent Reliable Spent Fuel Pool Instrumentation Overall Integrated Plan Overall Plan Reliability:

Reliability of of primary and backup instrument instrument channels channels will will be be assured assured byby conformance conformance with with the the guidelines ofof NRC JLD-ISG-2012-03 and and NEI 12-0212-02 as discussed below under Design Features and and Program Features. Both primary and backup level instrumentation channels will be functional at at all all times times when there is fuel in the SFP with allowance allowance for for maintenance, maintenance, testing, testing, or or repair as as described in NEI NEI 12 02. Reliability will will be be established established through through the the use use of of an an augmented augmented quality quality assurance assurance process process (e.g.,

(e.g., aa siInilar to process similar to that that applied applied to to the the site sitefire fire protection protectionprogram).

program).

Design Features Design Instrument Channel Design Criteria: Criteria: Instrument channel channel design design criteria criteria will will be be consistent consistentwith withthethe guidance guidance of of NRC NRC JLD-ISG-2012-03 JLD-ISG-2012-03and andNET NEI 12-02, 12-02.

Arrangement: The plan is to install SFP level level sensors sensors in the southeast southeast corner of of the Unit Unit 11 SFP SFP andand in the northeast corner corner of of the the Unit Unit 22 SFP; SFP; separated separatedby byaadistance distanceof ofapproximately approximately103 103feet.

feet.The The sensors themselves will be mounted, mounted, to to the the extent extentpractical, practical,nearnearthe thepool poolwalls wallsandandbelow belowthe thepool pool curb to minimize their exposure to damaging debris and and not not interfere with SFP activities.

activities. Instrument Instrument channel electronics and power supplies will be located in seismic seismic and and missile missile protected protected areas areas either below the SFP operating floor or in buildings other other than than the RB. RB. The Theareas areastotobe beselected selectedwillwillprovide provide suitable radiation shielding and environmental conditions for the equipment consistent with instrument manufacturer's recommendations. Equipment Equipmentand and cabling cabling for for power power supplies supplies andand indication for each channel will will be be separated separated equivalent equivalentto tothat thatprovided providedfor forredundant redundantsafety safetyrelated related services.

Mounting: Design of the mounting of of the the sensors sensors inin the the SFP SFPshall shallbe beconsistent consistentwithwiththetheseismic seismic Class I criteria. Installed Installedequipment equipmentwill willbe beverified verifiedtotobebeseismically seismicallyadequate adequatefor forthe theseismic seismic motions associated with the maximum seismic ground motion considered in the design design of of the plant area in which it is installed.

Qualification: Reliability of both instrument channels will be demonstrated via an appropriate combination of of design, analyses, analyses, operating operating experience, experience, and/or and/ortesting testingofofchannel channelcomponents componentsfor forthe the following sets of of parameters:

• conditions in the area of of instrument instrument channel channel component component use use for for all all instrument instrumentcomponents, components,

• + effects of shock and vibration on instrument channel components used during and effects and following following any applicable event, and

• seismic effects seismic effects on instrument instrument channel channel components components used used during and and following following aa potential potential seismic event.

Temperature, humidity and radiation levels consistent with the conditions in the vicinity of the SFP the area of use considering normal operation, and the operation, event event and and post-event post-event conditions conditions for for no nofewer fewerthanthan seven days post-event or until off-site resources can be deployed by the mitigating strategies can be deployed by the mitigating strategies resulting resulting 31 30

LaSalle LaSalle County County Station, Station, Units Units 1 and and 2 Reliable Reliable Spent Spent FuelFuel PoolPool Instrumentation Overall Overall Integrated Integrated Plan from Order from Order EA-12-049 EA-12-049 willwill be be addressed addressed in in the the detailed detailed design design engineering engineering phase of the the project.

project.

Examples of post-event (beyond-design-basis) conditions to be Examples be considered considered are:are:

• • radiological conditions radiological conditions for for aa normal normal refueling refueling quantity quantity of freshly discharged (100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />) fuel with with SFP water level level 3 as described in Order EA-12-051, EA-12-0SI,

• • temperature of 212 degrees F and 100% relative humidity environment, temperature environment,

• • boiling water boiling water and/or and/or steam steam environment, environment, and and

• • the impact of FLEX mitigating strategies.

Components of the Components the instrument instrument channels channels will be qualified for shock and vibration using one or more of of the following methods:

• components are components are supplied supplied by manufacturers manufacturers using using commercial commercial quality quality programs programs (such as as ISO9001, IS0900 1, "Quality management systems "Quality management systems-- Requirements")

Requirements") with with shock shock andand vibration vibration requirements included requirements included in in the purchase purchase specification specification at levels levels commensurate commensurate with with portable portable hand-held device or transportation applications; applications; and/or

• components have components have substantial history of operational substantial history operational reliability reliability inin environments environments with with significant shock and vibration vibration loadings, loadings, such such asas portable portablehand-held hand-helddevice deviceorortransportation transpOltation applications; and/or

• components are are inherently inherently resistant resistant to to shock shock and andvibration vibrationloadings, loadings,such suchasascables.

cables.

For seismic effects effects on on instrument inshument channel channel components componentsused usedafter afteraapotential potentialseismic seismicevent eventforforonly only installed installed components components (with (with the the exception exceptionof ofbattery batterychargers chargersand andreplaceable replaceablebatteries),

batteries),the thefollowing following measures will be be used used to verify that the design and and installation is adequate.

adequate. Applicable Applicablecomponents components are rated by the manufacturer manufacturer (or (or otherwise otherwise tested) tested) for for seismic seismic effects effects atatlevels levelscommensurate commensuratewith with those ofof postulated design basis eventevent conditions in the area area of of instrument channel channel component component use use using one one or or more more of ofthe the following following methods:

methods:

• Instrument channel components Instrument channel components use use known known operating principles and operating principles and are are supplied supplied by by manufacturers manufacturers with with commercial quality programs commercial quality programs (such(such as ISO9001).

IS0900l). The Theprocurement procurement specification specification and/or instrument channel design design shall include the seismic requirementsand shall include the seismic requirements and specify specify the need need forfor commercial commercial design design andand testing testing under underseismic seismicloadings loadingsconsistent consistentwith with design design basis basis values values atatthe theinstalled installedlocations.

locations.

• • Substantial Substantial history history ofof operational operational reliability reliability inin environments environments with withsignificant significantvibration, vibration, such such as for portable hand-held devices or transportation applications.

as for portable hand-held devices or transportation applications. Such Such aa vibration vibration design design 41 41P e

LaSalle County LaSalle County Station.

Station, UnitsUnits 11 and and 22 Reliable Reliable SpentSpent Fuel Fuel Pool Instrumentation Pool Instrumentation Overall Overall Integrated Integrated Plan envelope shall envelope shall bebe inclusive inclusive of the effects effects ofof seismic seismic motion motion imparted imparted to to the the components components proposed at the location of the proposed installation; proposed

• adequacyof adequacy of seismic seismic design design and and installation installation is is demonstrated demonstrated based based on on the guidance guidance in in Sections 7, Sections 7, 8, 8, 9, and and 10 10 ofofIEEE IEEEStandard Standard 344-2004, 344-2004, "IEEE "IEEE Recommended RecommendedPractice Practice forfor Seismic Qualification Seismic Qualification of of Class Class 1E IE Equipment for Nuclear Power Generating Stations", or aa substantially similar industrial standard; substantially

• • demonstration that demonstration that proposed proposed devices devices areare substantially substantially similar similar inin design design to models models thatthat have have been previously tested been previously tested for for seismic effects in excess of the plant design basis at the of the plant design basis at the location location where the instrument is to be installed installed (g-levels (g-levels and and frequency frequency ranges);

ranges); or or

• seismic qualification seismic qualification using using seismic seismic motion motion consistent consistent with with that that of existing existing design design basis basis loading at the installation location.

location.

Independence: The primary instrument channel will be independent of the backup instrument channel. This Thisindependence independencewill willbebeachieved achievedthrough throughphysical physicaland andelectrical electricalseparation separationof ofeach each channels' components components commensurate commensurate with with hazard hazard andand electrical electrical isolation isolation needs.

needs.

Power Supplies: Each channel will be normally powered from a different 120Vac bus. Upon Uponloss lossof of normal ac power, individual channel installed batteries will automatically maintain continuous channel operation. The Thebatteries batterieswill willbebereplaceable replaceableand andbebesized sizedto tomaintain maintainchannel channeloperation operationuntiluntil off-site resources can be deployed deployed by by the the mitigating mitigatingstrategies strategiesresulting resultingfromfromOrder OrderEA-12-049.

EA-12-049.

Additionally, each channel will have provisions for for connection to to another another suitable powerpower source.

source.

Accuracy:

Accuracy:The Theaccuracy accuracywill willbe beconsistent consistentwithwiththetheguidelines guidelinesofofNRC NRCJLD-ISG-2012-03 lLD-ISG-2012-03and andNEI NEI 12-02. The instrument channels will be designed to maintain their design accuracy following a power interruption or change in power power source source without without recalibration.

recalibration. Instrument Instrumentchannel channelaccuracy, accuracy,totobe be determined during detailed detailed design, design, will willconsider considerSpent SpentFuel FuelPool Poolconditions conditions(e.g.,

(e.g.,saturated saturatedwater, water, steam environment), as well as, other applicable radiological and environmental conditions and and include display accuracy.

accuracy. Instrument Instrumentchannel channelaccuracy accuracywillwillbebesufficient sufficienttotoallow allowtrained trainedpersonnel personneltoto determine when when thethe actual actual level level exceeds exceeds the the specified specifiedlower lowerlevel levelof ofeach eachindicating indicatingrange range(levels (levels1,1,22 or 3)

3) without without conflicting conflicting or orambiguous ambiguousindications.

indications.

Testing:

Testing:Instrument Instrument channel designdesign will will provide providefor forroutine routinetesting testingand andcalibration calibrationconsistent consistentwith withthe the guidelines guidelines of of NRC NRC JLD-ISG-2012-03 lLD-ISG-2012-03 and and NEI NEI 12-02.

12-02. Details Detailswillwillbebedetermined determinedduringduringdetailed detailed design design engineering.

engineering.

Display:

Display: The display(s) display(s) will will be be consistent consistent withwith the the guidelines guidelines of ofNRC NRC JLD-ISG-2012-03 lLD-ISG-2012-03 and and NEINEI 12-12-02.

02.

The The primary primary and and backup backupinstrument instrumentdisplays displayswill willbe belocated locatedatatthethecontrol controlroom, room,remote remoteshutdown shutdown

panel, panel, oror other other appropriate appropriate and and accessible accessible location.

location. TheThespecific specificlocation locationwill willbe bedetermined determinedduring during detailed design.

detailed design. An An appropriate appropriateand andaccessible accessiblelocation locationwillwillinclude includethe thefollowing followingcharacteri sties:

characteristics:

• occupied occupied or or promptly promptly accessible accessible to to the theappropriate appropriate plant plantstaff staffgiving givingappropriate appropriate consideration consideration to to various various drain drain down down scenarios, scenarios, 51 5IPag e

LaSalle LaSalle County County Station, Station, Units Units 1 and 2 Reliable Reliable Spent Spent FuelFuel Pool Instrumentation Pool Instrumentation Overall Integrated Plan

• outside the area surrounding

• outside the the area SFP floor the surrounding (e.g.,

SFPan floorappropriate distance (e.g., an appropriate fromfrom distance the the radiological radiological sources resulting from an event impacting the Spent Spent Fuel Fuel Pool),

Pool),

• inside a structure providing protection protection against adverse weather, and

• outside of any outside any very high high radiation radiation areas areas or LOCKED LOCKED HIGH RAD RAD AREAAREA during during normal normal operation.

Program Features:

The program criteria will be consistent with the guidelines of NRC JLD-ISG-2012-03 and NEI 12-02. 12-02.

Training: Personnel performing functions associated associated with with these these SFP SFP level levelinstrumentation instrumentationchannels channels will be trained to perform the job specific specific functions functions necessary necessary for for their theirassigned assignedtasks tasks(maintenance, (maintenance, etc.). This calibration, surveillance, etc.). This training training will will bebe consistent consistentwithwithequipment equipmentvendorvendorguidelines, guidelines, instructions and recommendations. The The Systematic Systematic Approach Approach to to Training Training(SAT) (SAT)willwillbe beused usedtoto identify the population to be trained and to determine the initial and continuing elements of the training. Training required training. Training will will be becompleted completedpriorpriorto to placing placingthetheinstrumentation instrumentationininservice.

service.

Procedures: Procedures will be developed using guidelines and vendor instructions to address the maintenance, operation and abnormal response response issues issues associated associated withwiththetheprimary primaryand andbackup backup channels ofof SFP instrumentation.

Procedures will also address the following following situations:

situations:

• at the time If, at time of of an an event event or orthereafter thereafter until until the the unit unit isisreturned returnedtotonormal normalservice, service, anan channel ceases instrument channel ceases to function, function, its function will be be recovered recovered within within aa period period ofoftime time consistent with the emergency conditionsconditions thatthat may may exist exist atat the the time.

time.

• If, at at the time time of of an an event event or orthereafter thereafter until until the the unit unitisisreturned returnedtotonormal normalservice, service, anan instrument channel component instrument channel component must must bebe replaced, replaced, it maymay be be replaced replaced with with aacommercially commercially available component available componentthat thatmayor may or may may not not meet meet all of of the the qualifications qualifications noted noted above above toto maintain instrument channel functionality.

functionality.

Testing and Calibration: Processes shall be established and maintained for scheduling and implementing necessary testingtesting and and calibration calibration of ofthe the primary primaryand andbackup backupSFP SFPlevel levelinstrument instlument channels to maintain the instrument instrument channels channels at at the the design design accuracy.

accuracy. The Thetesting testingandandcalibration calibrationofofthe the instrumentation shall be be consistent consistent with with vendor vendor recommendations recommendationsor orother otherdocumented documentedbasis.basis.

Calibration shall be specific specific toto the the mounted mounted instrument instrumentand andthethemonitor.

monitor.

Surveillances or testing to validate validate functionality functionality of ofan an installed installedinstrument instrumentchannel channelshall shallbe beperformed performed within 60 days of of a planned planned refueling refueling outage outage considering consideringnormalnormaltesting testingscheduling schedulingallowances allowances(e.g.,

(e.g.,

25%). This Thisisisnot notrequired requiredto tobebeperformed performedmoremorethan thanonce onceper per1212months.

months.

The primary or or back-up instrument instrument channel channel can canbe beout outof ofservice servicefor fortesting, testing,maintenance maintenanceand/or and/or calibration for up to 90 days days provided provided thethe other otherchannel channel isisfunctional.

functional.Additionally, Additionally,compensatory compensatory actions must be taken if if the the instrumentation instrumentation channel channel isis notnotexpected expectedtotobe berestored restoredororisisnot notrestored restored within 90 days. IfIfboth bothchannels channelsbecome becomenon-functioning non-functioningthen theninitiate initiateactions actionswithin within24 24hours hourstoto 61 P 61

LaSalle LaSalle County County Station, Station. Units Units 11 and and 22 Reliable Reliable Spent Spent FuelFuel Pool Pool Instrumentation Overall Overall Integrated Integrated Plan Plan restore one restore one ofof the the channels channels ofof instrumentation instrumentation and and implement implement compensatory compensatory actions actions (e.g.,

(e.g., use use of alternate suitable alternate suitable equipment equipment or supplemental personnel) within within 72 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

hours.

If aa single If single SFP SFP forfor the the purposes purposes of this this order isis divided by by the closure of a normally open gate(s) gate(s) such that aa portion that portion of thethe SFP containing fuel fuel used for power production within the last five five years years is no longer able longer able to to be be monitored monitored by by a required SFP instrumentation channel, channel, then then the the actions actions described above must above must bebe taken for the impacted instrumentation instrumentation channel.

channel.

Need for Relief and Basis:

Need Exelon is notnot requesting requesting relief relieffrom from the the requirements requirements of Order EA EA-12-051 051 or the guidance guidance inin NRC JLD-ISG-2012-03 at at this this time.

time, requirements of Order EA-12-051 Consistent with the requirements EA-12-051 and the guidance in NEI 12-02, Exelon's Exelon's six-month six-month reports will delineate progress made, any proposed changes in compliance methods, updates to the reports schedule, and if needed, requests for relief relief and and their their basis.

basis.

References:

1. NRC Order Number EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel

1. Fuel Pool Instrumentation, Instrumentation , dated March 12, 2012 12,2012

2. NRC Interim Staff Guidance JLD-ISG-2012-03, Compliance with

2. with Order Order EA-12-051, Order Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation, Instrumentation, Revision 0, dated August 29, 2012

3. NEI 12-02, Industry Guidance for Compliance with NRC

3. NRC Order EA-12-051, "To "To Modify Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," Revision 1, 1, dated August August 24, 2012

4. NRC Order Number EA-12-049, Order Order Modifying Modifying Licenses Licenses with with Regard Regard toto Requirements Requirements for for Mitigating Strategies for Beyond-Design-Basis External Events, Events, dated March 12, 2012 12,2012 71 71